M/S. RALLIS INDIA LTD ,MUMBAI vs. DCIT, 8(1)(1), MUMBAI

ITA 7688/MUM/2025Status: DisposedITAT Mumbai11 February 2026AY 2022-23Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the adjustment made by the CPC was unsustainable as it was made without a show cause notice. Furthermore, a Hon'ble High Court had quashed the intimation containing this ICDS adjustment. Therefore, the consequential addition made in the assessment order under Section 143(3) must be deleted.

What were the facts?

The assessee, Rallis India Limited, engaged in agrochemicals and agri services, filed its return of income for AY 2022-23. The CPC made an adjustment of Rs. 1284.66 crores on account of ICDS, significantly higher than the assessee's suo motu adjustment. The assessee contested this adjustment through rectification and appeals.

What were the issues?

Whether the addition of Rs. 1284.66 crores on account of ICDS adjustment by the CPC was valid and whether the assessment order under Section 143(3) could sustain this addition after the High Court quashed the intimation under Section 143(1)(a).

Which sections of the Income-tax Act were involved?

Section 143(1),Section 143(1)(a),Section 143(2),Section 143(3),Section 154,Section 134B,Section 134C,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “D” BENCH, MUMBAI

For Appellant: Shri Percy J Pardiwalla and Shri Jeet Kamdar
For Respondent: Shri Umashankar Prasad
Hearing: 09.02.2026Pronounced: 11.02.2026

Per Saktijit Dey, Vice President:

Captioned appeal by the assessee arises out of the order dated 27.09.2025, passed by National Faceless Appeal Centre (‘NFAC’ for short), Delhi for the assessment year (A.Y. for short) 2022-23. 2. Though, the assessee has raised multiple grounds, however, the core issue arising in appeal relates to addition of an amount of Rs.1284.66 crores on account of adjustments under Income Computation and Disclosure Standards (‘ICDS’ for short).

3.

Relevant facts necessary for deciding this issue are, the assessee is a resident corporate entity stated to be engag

The order continues below.

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